Safety and Health Programs: Recommended Practices (OSHA 3885)

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1. Page 1

   Management Leadership

   • Worker Participation
   • Find and Fix Hazards
   • Recommended Practices for
   • Safety and Health
   • Programs
   • Occupational Safety
   • and Health Administration osha.gov/safetymanagement
   • OSHA 3885
   • October 2016
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   DISCLAIMER

   • These practices for safety and health programs are recommendations only. Employers are not required to have a safety and health program that complies with them and will not be cited for failing to have a safety and health program that complies with this document.
   • These recommended practices apply to employers, except in the construction industry, for whom there are separate Recommended Practices for Safety and Health Programs for the Construction Industry.
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   FOREWORD

   • FOREWORD
   • Establishing a safety and health program in your workplace is one of the most effective ways of protecting your most valuable asset: your workers. Losing workers to injury or illness, even for a short time, can cause significant disruption and cost—to you as well as the workers and their families. It can also damage workplace morale, productivity, turnover, and reputation.
   • Resources and Tools to Support
   • Implementation of These
   • Recommended Practices
   • OSHA has created a dedicated Web page to support the implementation of these recommended practices at osha.gov/ safetymanagement. The page includes the following:
   • Safety and health programs foster a proactive approach to “finding and fixing” workplace hazards before they can…
   • …
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   FOREWORD

   • There is greater recognition that workers in industries that some think of as safe (such as healthcare, lodging, retail, and transportation) face significant hazards.
   • Increased temporary and contract employment, and the rise of the “gig economy” mean that traditional relationships between workers and employers are shifting, and changes in safety programs and policies will be required to ensure the safety of all workers at worksites characterized by these newer and more fluid relationships.
   • ii
   • These new recommended practices reflect these changes. They also reflect what we have learned from best-in-class programs and what makes them effective. …
   • …
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   CONTENTS

   • INTRODUCTION … 2
   • MANAGEMENT LEADERSHIP … 9
   • WORKER PARTICIPATION … 11
   • HAZARD IDENTIFICATION AND ASSESSMENT … 15
   • HAZARD PREVENTION AND CONTROL … 20
   • EDUCATION AND TRAINING … 24
   • PROGRAM EVALUATION AND IMPROVEMENT … 27
   • COMMUNICATION AND COORDINATION FOR HOST EMPLOYERS, CONTRACTORS,
   • AND STAFFING AGENCIES … 30
   • LIST OF ABBREVIATIONS … 34
   • GLOSSARY OF TERMS … 34
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   INTRODUCTION

   • THESE RECOMMENDED PRACTICES provide responsible employers, workers, and worker representatives 3 with a sound, flexible framework for addressing safety and health issues in diverse workplaces. They may be used in any workplace, but will be particularly helpful in small and medium-sized workplaces. They can be applied equally well in traditional, fixed manufacturing workplaces and in the
   • service sector, healthcare, retail, and even mobile or office-based work environments. They also include information specifically aimed at temporary worker and multiemployer work situations. Separate recommended practices are available for the construction industry.
   • Worker participation is vital to the success of the program. …
   • …
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   THE BENEFITS OF IMPLEMENTING THESE RECOMMENDED PRACTICES

   • INTRODUCTION
   • The recommended practices emphasize a proactive approach to managing workplace safety and health. Traditional approaches are often reactive—that is, actions are taken only after a worker is injured or becomes sick, a new standard or regulation is published, or an outside inspection finds a problem that must be corrected. Finding and fixing hazards before they cause injury or illness is a far more effective approach. Doing so avoids the direct and indirect costs of worker injuries and illnesses, and promotes a positive work environment.
   • The concept of continuous improvement is central to the recommended practices. As with any journey, the first step is often the most…
   • …
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   IMPLEMENTING

   • INTRODUCTION
   • a safety & health program can help employers avoid the INDIRECT
   • COSTS
   • that result from
   • WORKPLACE
   • INCIDENTS
   • such as
   • TIME LOST
   • due to work stoppages and investigations, training and other costs associated with REPLACING
   • INJURED
   • WORKERS
   • LOSS OR and DAMAGE to material, machinery and property.
   • These INDIRECT have been estimated
   • 2.7
   • to be at least times the
   • COSTS
   • DIRECT
   • COSTS
   • Source: Leigh, J.P. (2011), Economic Burden of Occupational Injury and Illness in the United States. Milbank Quarterly, 89:728-772. 4
   • HOW TO USE THE RECOMMENDED
   • PRACTICES
   • have implemented (or will implement) each action item.
   • Each section of the recommended practices describes a core program element (see page
   • …
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   10 EASY THINGS TO GET YOUR PROGRAM STARTED

   • INTRODUCTION
   • If these recommended practices appear challenging, here are some simple steps you can take to get started. Completing these steps will give you a solid base from which to take on some of the more structured actions presented in the recommended practices.
   • 1. SET SAFETY AND HEALTH AS A TOP PRIORITY
   • 6. COLLECT HAZARD CONTROL
   • IDEAS
   • Always set safety and health as the top priority. Tell
   • Ask workers for ideas on improvements and follow up your workers that making sure they finish the day and on their suggestions. Provide them time during work go home safely is the way you do business. Assure hours, if necessary, to research solutions.
   • them that you will work with them to find and fix any
   • …
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    One size does not fit all

    • INTRODUCTION
    • participants. Thus, the “Education and Training” core element supports the “Worker Participation” core element. Similarly, setting goals (as described under “Management Leadership”) will be more effective if you routinely evaluate your progress in meeting those goals (see “Program Evaluation and Improvement”). Progress in each core element is important to achieve maximum benefit from the program.
    • While the action items under each core element are specific, they are not prescriptive. The process described in these recommended practices can, and should, be tailored to the needs of each workplace. Likewise, your safety and health program can and should evolve. …
    • …
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    CORE ELEMENTS OF THE SAFETY AND HEALTH PROGRAM RECOMMENDED PRACTICES

    • INTRODUCTION
    • MANAGEMENT LEADERSHIP
    • Top management demonstrates its commitment to continuous improvement in safety and health, communicates that commitment to workers, and sets program expectations and responsibilities.
    • Managers at all levels make safety and health a core organizational value, establish safety and health goals and objectives, provide adequate resources and support for the program, and set a good example.
    • Workers and their representatives are involved in all aspects of the program—including setting goals, identifying and reporting hazards, investigating incidents, and tracking progress.
    • WORKER
    • PARTICIPATION
    • …
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    FOR MORE INFORMATION

    • INTRODUCTION
    • For more information about these recommended practices, tools to help you implement them, and related topics, see the recommended practices Web page. This page includes links to many tools and resources developed by OSHA and others that can help employers and workers implement these recommended practices. OSHA will continue to update and add to this resource list.
    • On-site Consultation Program services are separate from enforcement and do not result in penalties or citations. Consultants from state agencies or universities work with employers to identify workplace hazards, provide advice on compliance with OSHA standards, and help them establish and improve their safety and health programs.
    • …
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    MANAGEMENT LEADERSHIP

    • MANAGEMENT PROVIDES the leadership, vision, and resources needed to implement an effective safety and health program.
    • Management leadership means that business owners, managers, and supervisors:
    • Make worker safety and health a core organizational value.
    • Are fully committed to eliminating hazards, protecting workers, and continuously improving workplace safety and health.
    • Provide sufficient resources to implement and maintain the safety and health program.
    • Visibly demonstrate and communicate their safety and health commitment to workers and others.
    • Set an example through their own actions.
    • Action item 1: Communicate your commitment to a safety and health program
    • …
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    Action item 2: Define program goals

    • MANAGEMENT LEADERSHIP
    • By establishing specific goals and objectives, management sets expectations for managers, supervisors, and workers, and for the program overall. The goals and objectives should focus on specific actions that will improve workplace safety and health.
    • How to accomplish it
    • Establish realistic, measurable goals for improving safety and health. Goals emphasizing injury and illness prevention should be included, rather than focusing on injury and illness rates.
    • Develop plans to achieve the goals by assigning tasks and responsibilities to particular people, setting timeframes, and determining resource needs.
    • Action item 3: Allocate resources
    • …
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    WORKER PARTICIPATION

    • TO BE EFFECTIVE, any safety and health program needs the meaningful participation of workers and their representatives. Workers have much to gain from a successful program, and the most to lose if the program fails. They also often know the most about potential hazards associated with their jobs. Successful programs tap into this knowledge base.
    • Worker participation means that workers are involved in establishing, operating, evaluating, and improving the safety and health program. All workers at a worksite should participate, including those employed by contractors, subcontractors, and temporary staffing agencies (see “Communication and Coordination for Host Employers, Contractors, and Staffing Agencies”).
    • …
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    Action item 1: Encourage workers to participate in the program

    • WORKER PARTICIPATION
    • By encouraging workers to participate in the program, management signals that it values their input into safety and health decisions.
    • How to accomplish it
    • Give workers the necessary time and resources to participate in the program.
    • Acknowledge and provide positive reinforcement to those who participate in the program.
    • Maintain an open door policy that invites workers to talk to managers about safety and health and to make suggestions.
    • Action item 2: Encourage workers to report safety and health concerns
    • Workers are often best positioned to identify safety and health concerns and program shortcomings, such as emerging workplace hazards, unsafe conditions…
    • …
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    Action item 4: Involve workers in all aspects of the program

    • WORKER PARTICIPATION
    • Results of environmental exposure monitoring conducted in the workplace
    • (prevent disclosure of sensitive and personal information as required)
    • Chemical and equipment manufacturer safety recommendations
    • Other useful information for workers to review can include:
    • Incident investigation reports (prevent disclosure of sensitive and personal information as required)
    • Workplace inspection reports
    • Workplace job hazard analyses
    • Including worker input at every step of program design and implementation improves your ability to identify the presence and causes of workplace hazards, creates a sense of program ownership among workers, enhances their understanding of how the…
    • …
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    Action item 5: Remove barriers to participation

    • WORKER PARTICIPATION
    • To participate meaningfully in the program, workers must feel that their input is welcome, their voices will be heard, and they can access reporting mechanisms. Participation will be suppressed if language, education, or skill levels in the workplace are not considered, or if workers fear retaliation or discrimination for speaking up (for example, if investigations focus on blaming individuals rather than the underlying conditions that led to the incident, or if reporting an incident or concern could jeopardize the award of incentive-based prizes, rewards, or bonuses).
    • How to accomplish it
    • Ensure that workers from all levels of the organization can participate regardless of…
    • …
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    HAZARD IDENTIFICATION AND ASSESSMENT

    • ONE OF THE “root causes” of workplace injuries, illnesses, and incidents is the failure to identify or recognize hazards that are present, or that could have been anticipated. A critical element of any effective safety and health program is a proactive, ongoing process to identify and assess such hazards.
    • TO IDENTIFY AND ASSESS hazards, employers and workers:
    • Consider hazards associated with emergency or nonroutine situations.
    • Collect and review information about the hazards present or likely to be present in the workplace.
    • Conduct initial and periodic workplace inspections of the workplace to identify new or recurring hazards.
    • …
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    HAZARD IDENTIFICATION AND ASSESSMENT

    • SDSs provided by chemical manufacturers.
    • Input from workers, including surveys or minutes from safety and health committee meetings.
    • Self-inspection reports and inspection reports from insurance carriers, government agencies, and consultants.
    • Records of previous injuries and illnesses, such as OSHA 300 and 301 logs and reports of incident investigations.
    • Results of job hazard analyses (JHAs, also known as job safety analyses or JSAs).
    • Workers’ compensation records and reports.
    • Information about hazards may be available from outside sources, such as:
    • OSHA, National Institute for Occupational Safety and Health (NIOSH), and Centers for Disease Control and Prevention (CDC) websites, publications, and alerts.
    • …
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    HAZARD IDENTIFICATION AND ASSESSMENT

    • Electrical hazards
    • Workplace violence
    • Equipment operation
    • Ergonomic problems
    • Equipment maintenance
    • Lack of emergency procedures
    • Fire protection
    • Work organization and process flow (including staffing and scheduling)
    • Work practices
    • Before changing operations, workstations, or workflow; making major organizational changes; or introducing new equipment, materials, or processes, seek the input of workers and evaluate the planned changes for potential hazards and related risks.
    • Note: Many hazards can be identified using common knowledge and available tools. For example, you can easily identify and correct hazards associated with broken stair rails and frayed electrical cords. …
    • …
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    Action item 4: Conduct incident investigations

    • HAZARD IDENTIFICATION AND ASSESSMENT
    • Identify biological hazards—determine whether workers may be exposed to sources of infectious diseases, molds, toxic or poisonous plants, or animal materials (fur or scat) capable of causing allergic reactions or occupational asthma.
    • Identify ergonomic risk factors—examine work activities that require heavy lifting, work above shoulder height, repetitive motions, or tasks with significant vibration.
    • Conduct quantitative exposure assessments, when possible, using air sampling or direct reading instruments.
    • Review medical records to identify cases of musculoskeletal injuries, skin irritation or dermatitis, hearing loss, or lung disease that may be related to…
    • …
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    Action item 5: Identify hazards associated with emergency and nonroutine situations

    • HAZARD IDENTIFICATION AND ASSESSMENT
    • Emergencies present hazards that need to be recognized and understood. Nonroutine or infrequent tasks, including maintenance and startup/shutdown activities, also present potential hazards. Plans and procedures need to be developed for responding appropriately and safely to hazards associated with foreseeable emergency scenarios and nonroutine situations.
    • How to accomplish it
    • Identify foreseeable emergency scenarios and nonroutine tasks, taking into account the types of material and equipment in use and the location within the facility. Scenarios such as the following may be foreseeable:
    • …
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    HAZARD PREVENTION AND CONTROL

    • EFFECTIVE CONTROLS protect workers from workplace hazards; help avoid injuries, illnesses, and incidents; minimize or eliminate safety and health risks; and help employers provide workers with safe and healthful working conditions. The processes described in this section will help employers prevent and control hazards identified in the previous section.
    • TO EFFECTIVELY CONTROL and prevent hazards, employers should:
    • Involve workers, who often have the best understanding of the conditions that create hazards and insights into how they can be controlled.
    • Identify and evaluate options for controlling hazards, using a “hierarchy of controls.”
    • …
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    Action item 2: Select controls

    • HAZARD PREVENTION AND CONTROL
    • Get input from workers who may be able to suggest and evaluate solutions based on their knowledge of the facility, equipment, and work processes.
    • For complex hazards, consult with safety and health experts, including OSHA’s On-site Consultation Program.
    • Employers should select the controls that are the most feasible, effective, and permanent.
    • Most effective
    • Hierarchy of Controls
    • Elimination
    • How to accomplish it
    • Eliminate or control all serious hazards (hazards that are causing or are likely to cause death or serious physical harm) immediately.
    • Use interim controls while you develop and implement longer-term solutions.
    • …
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    Action item 4: Select controls to protect workers during nonroutine operations and emergencies

    • HAZARD PREVENTION AND CONTROL
    • Establish a target completion date.
    • Plan how you will track progress toward completion.
    • Plan how you will verify the effectiveness of controls after they are installed or implemented.
    • The hazard control plan should include provisions to protect workers during nonroutine operations and foreseeable emergencies. Depending on the workplace, these could include fires, explosions, chemical releases, hazardous material spills, unplanned equipment shutdowns, infrequent maintenance activities, natural and weather disasters, workplace violence, terrorist or criminal attacks, disease outbreaks (e.g., pandemic influenza), or…
    • …
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    Action item 6: Follow up to confirm that controls are effective

    • HAZARD PREVENTION AND CONTROL
    • To ensure that control measures are and remain effective, employers should track progress in implementing controls, inspect and evaluate controls once they are installed, and follow routine preventive maintenance practices.
    • How to accomplish it
    • Track progress and verify implementation by asking the following questions:
    • Have all control measures been implemented according to the hazard control plan?
    • Conduct regular inspections (and industrial hygiene monitoring, if indicated) to confirm that engineering controls are operating as designed.
    • Evaluate control measures to determine if they are effective or need to be modified.
    • …
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    EDUCATION AND TRAINING

    • EDUCATION AND TRAINING are important tools for informing workers and managers about workplace hazards and controls so they can work more safely and be more productive. Another role of education and training, however, is to provide workers and managers with a greater understanding of the safety and health program itself, so that they can contribute to its development and implementation.
    • EDUCATION AND TRAINING provides employers, managers, supervisors, and workers with:
    • Knowledge and skills needed to do their work safely and avoid creating hazards that could place themselves or others at risk.
    • Awareness and understanding of workplace hazards and how to identify, report, and control them.
    • …
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    EDUCATION AND TRAINING

    • How to report hazards, injuries, illnesses, and close calls/near misses
    • Ensure that training is provided in the language(s) and at a literacy level that all workers can understand.
    • Emphasize that the program can only work when everyone is involved and feels comfortable discussing concerns; making suggestions; and reporting injuries, incidents, and hazards.
    • Confirm, as part of the training, that all workers have the right to report injuries, incidents, hazards, and concerns and to fully participate in the program without fear of retaliation.
    • What to do in an emergency
    • The employer’s responsibilities under the program
    • Workers’ rights under the OSH Act
    • …
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    Action item 3: Train workers on their specific roles in the safety and health program

    • EDUCATION AND TRAINING
    • Additional training may be needed to ensure that workers can incorporate any assigned safety and health responsibilities into their daily routines and activities.
    • How to accomplish it
    • Instruct workers on how to report injuries, illnesses, incidents, and concerns. If a computerized reporting system is used, ensure that all employees have the basic computer skills and computer access sufficient to submit an effective report.
    • Instruct workers assigned specific roles within the safety and health program on how they should carry out those responsibilities, including:
    • Participation in incident investigations
    • …
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    PROGRAM EVALUATION AND IMPROVEMENT

    • ONCE A SAFETY and health program is established, it should be evaluated initially to verify that it is being implemented as intended. After that, employers should periodically, and at least annually, step back and assess what is working and what is not, and whether the program is on track to achieve its goals. Whenever these assessments identify opportunities to improve the program, employers, managers, and supervisors—in coordination with workers—should make adjustments and monitor how well the program
    • PROGRAM EVALUATION and improvement includes:
    • Establishing, reporting, and tracking goals and targets that indicate whether the program is making progress.
    • …
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    PROGRAM EVALUATION AND IMPROVEMENT

    • Track leading indicators, such as:
    • Timely completion of corrective actions after a workplace hazard is identified or an incident occurs
    • Timely completion of planned preventive maintenance activities
    • Worker opinions about program effectiveness obtained from a safety climate or safety opinion survey
    • Level of worker participation in program activities
    • Number of employee safety suggestions
    • Number of hazards, near misses, and first aid cases reported
    • Amount of time taken to respond to reports
    • Analyze performance indicators and evaluate progress over time.
    • Number and frequency of management walkthroughs
    • Number and severity of hazards identified during inspections
    • …
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    Action item 3: Correct program shortcomings and identify opportunities to improve

    • PROGRAM EVALUATION AND IMPROVEMENT
    • Review the results of any compliance audits to confirm that any program shortcomings are being identified. Verify that actions are being taken that will prevent recurrence.
    • Whenever a problem is identified in any part of the safety and health program, employers—in coordination with supervisors, managers, and workers—should take prompt action to correct the problem and prevent its recurrence.
    • How to accomplish it
    • If you discover program shortcomings, take actions needed to correct them.
    • Proactively seek input from managers, workers, supervisors, and other stakeholders on how you can improve the program.
    • …
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    COMMUNICATION AND COORDINATION FOR HOST EMPLOYERS, CONTRACTORS, AND STAFFING AGENCIES

    • IN TODAY’S ECONOMY, an increasing number of workers are assigned by staffing agencies to work at specific “host” worksites under the direction and control of the host employer. Examples include seasonal workers, such as delivery drivers and warehouse workers, who help fill a temporary staffing need, as well as office and production workers who may be placed in both short- and long-term assignments. In these situations, it is important for the staffing agency and the host employer to communicate and coordinate to provide and maintain a safe work environment for their workers.
    • In other situations, some workers are employed by a host employer and others by a…
    • …
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    Definitions

    • COMMUNICATION AND COORDINATION FOR HOST EMPLOYERS, CONTRACTORS, AND STAFFING AGENCIES
    • Host employers and their workers are aware of:
    • The types of hazards that may arise from the work being done on site by workers employed by contractors or staffing agencies.
    • The procedures or measures needed to avoid or control exposure to these hazards.
    • How to contact the contract or staffing firm if they have a safety concern.
    • What to do in case of an emergency.
    • Host employer: An employer who has general supervisory authority over the worksite, including controlling the means and manner of work performed and having the power to correct safety and health hazards or require others to correct them.
    • …
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    Action item 1: Establish effective communication

    • COMMUNICATION AND COORDINATION FOR HOST EMPLOYERS, CONTRACTORS, AND STAFFING AGENCIES
    • Each host employer establishes and implements a procedure to ensure the exchange of information about hazards present on site and the hazard control measures in place. Thus, all workers on the site are aware of worksite hazards, and the methods and procedures needed to control exposures to them.
    • How to accomplish it
    • The host employer communicates with contractors and staffing agencies to determine which among them will implement and maintain the various parts of the safety and health program, to ensure protection of all on-site workers before work begins. …
    • …
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    Action item 2: Establish effective coordination

    • COMMUNICATION AND COORDINATION FOR HOST EMPLOYERS, CONTRACTORS, AND STAFFING AGENCIES
    • Host employers, contractors, and staffing agencies coordinate on work planning, scheduling, and resolving program differences to identify and work out any concerns or conflicts that could impact safety or health.
    • How to accomplish it
    • Host employers:
    • Include in contracts and bid documents any safety-related specifications and qualifications and ensure that contractors and staffing agencies selected for the work meet those requirements.
    • Identify issues that may arise during on-site work and include procedures to be used by the host employer and contractors and/or staffing agencies for resolving any conflicts…
    • …
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    LIST OF ABBREVIATIONS

    • CDC
    • Centers for Disease Control and Prevention
    • NIOSH
    • National Institute for Occupational Safety and Health
    • OSHA
    • Occupational Safety and Health Administration
    • PPE
    • personal protective equipment
    • PtD
    • Prevention through Design
    • SDS
    • Safety Data Sheet
    • SHARP
    • Safety and Health Achievement Recognition Program
    • VPP
    • Voluntary Protection Programs
    • GLOSSARY OF TERMS
    • close call/near miss:
    • An incident that could have, but did not, result in death, injury, or illness. They signal that hazards are not being adequately controlled or that new hazards have arisen.
    • contractor:
    • An individual or firm that agrees to furnish materials or perform services at a specified price.
    • elimination:
    • …
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    • GLOSSARY OF TERMS
    • host employer:
    • An employer who has general supervisory authority over the worksite, including controlling the means and manner of work performed and having the power to correct safety and health hazards or require others to correct them.
    • industrial hygiene:
    • The science of protecting and enhancing the health and safety of people at work and in their communities.
    • job hazard analysis:
    • A technique that focuses on job tasks as a way to identify hazards before they occur. It focuses on the relationships among the worker, the task, the tools, and the work environment.
    • joint-employed worker:
    • A worker hired and paid by a staffing agency and assigned to work for a host employer, whether or not the job is actually temporary.
    • …
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    GLOSSARY OF TERMS

    • Safety and Health Achievement
    • Recognition Program:
    • An OSHA program that recognizes small business employers who have used OSHA's On-site Consultation Program services and operate an exemplary injury and illness prevention program.
    • safety data sheet:
    • Written or printed material used to communicate the hazards of substances and chemical products to employees prepared in accordance with paragraph (g) of OSHA’s Hazard Communication standard.
    • serious hazards:
    • Hazards that are causing or are likely to cause death or serious physical harm. See OSHA’s Field Operations Manual, Chapter 4.
    • shortcoming:
    • A fault, deficiency, or gap that results in a failure to meet program design criteria.
    • staffing agency:
    • …